ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

153A was required to be issued but only under section 148, then we have to appreciate whether conditions for reopening the assessment are available or not. In this connection, we deem it appropriate to take note of the relevant part of the section 147 of the Income Tax Act, which reads as under:- “147. Income escaping assessment: If the Assessing